" - ?/:). 1'1' )r' ", " J ~I ( ""., " .)OC)

1. CompanylProduct Number 2. £PI'. Product Moneger 3. Propo~edt~flcation 19713·301 Cynthia Giles·Parker o No":"... • 0 lIeotricted 4. CompanylProduct (Neme) PM' • •• DREXEL KOP-HYDROXIDE 221Fungicide Branch •• • • 0 5. Name and Addr••• of Applicant (lnclud. ZIP Cod_' 6. Expedited Reveiw. In accordance llfith• A~ ~ion 3(c1(31 (bWI. my product is similar or lderftft:;lf III compflsition and labeling to: .. •••• Drexel Chemical Company, P.O. Box 13327 0 0 • EPA Reg. No. • •••• 0 0 • .. MEMPHIS, TN 38113-0327 ••••• • Ch."k if _ i8 • n_ edflrou •••• o Product Name 0 • , Section - II •••• •••• RMI'printed lobeI.ln __ to 0 Amendment· Explain below. ~ A_ie__ 0 R•• ubmi .. ion in reapon•• to Agency lener dated 0 -Me Too· Application. NO IIFICAT/ON 0 Notification - Explain below. D Other - Explain below. JUN 3 0 2004 Explanation: U•• additional pageCs' if nec ••••ry. (For section I and Section II.)

One (1) copy of the revised label (301 SP-06Q4++) is submitted for your record and file. Details of the changes are on the cover letter accompanying this submission. The required certification statement is also submitted. Thank you.

Section - III 1. M.torIai Thio __ Be Po,*_d In:

Child-Resistant Packaging Unit Packaging Water Soluble Pockoging 2. Type of Conteiner Ye...... tlc By'·No No a:· B GI •• If -Ve.- No. per If -Ves- No. por p ..... • Certificlltion mullt Unit Peckaging wgt. container Pock.go wgt _nor Other (Specify) bellubmitted ~r I 3. Location of Net Contents Information 4. Size{.) Retail Container 5. Looetion of t..beI DlrectioM L Lebel 1 J ConUiner l=:l 8. Manner in Which Labat I. Affixed to Product 8Uthogroph Other .- P.... rt.:: ed 0 Stenclitd Section -IV

,. Contact Point (Comp/et. itenw dinctly billow for identific.tion of indlvitJual to .. contllt:Nd, If Me y.m_W.~.1

Nam. Title Telephone No. (Include 1'._ Cod.1 LUZGCHAN REGISTRATION MANAGER (901) IT4-4370

Certification I. Dote AppIi_ I certify that the atatement. I have mede on thie form end aU attechmentt: thereto .. true. .acur.te and complete. I acknowledge that any knowlinglly false or misleading statement may be punishable by Ii,. 01 impriHrvnent or II-(Stampedl both under IIPpiialibl. law.

3. Title 2. Signotu"a~. .,.. . d?.V')-V' REGISTRATION MANAGER

4. Typed N..... V 5. Oat. LUZGCHAN June 14, 2004

EPA Form 8670.1 ,Rev. 3-941 Previous editions are obsoletl. __ ·I!PA Flo Copy ' ...... , y .... - Ap, ••It Copy "".....-.;'"-,...-,.--"'"

NOT/F/CA1JO:h JUN 3 0 2004 Drexel Chemical Company .., .. • •••• • •••• • •• ••• ••••••• •• • May 27, 2004 • • • • •••••• ••••••• • •• • • ••• ••••• • •• ••• •••••• • • •••• • •••• • Submission ofRevised Label per PR Notice 98-10 •••• DREXEL KOP-HYDROXIDE (EPA Reg. No. 19713-301) •••••

This notification is consistent with the Provisions of PR Notice 98-10 and EPA Regulations at 40 CFR 152.46, and no other changes have been made to the labeling or the Confidential Statement of Formula of this product. I understand that it is a violation of 18 U.S.C. Sec. 1001 to willfully make any false statement to EPA. I further understand that if this notification is not consistent with the terms of PR Notice 98-10 and 40 CFR 152.46, this product may be in violation ofFIFRA and I may be subject to enforcement action and penalties under Sections 12 and 14 ofFIFRA.

FOR DREXEL CHEMICAL COMPANY

1700 Channel Avenue· Post Office Box t3327 • MemphiS, Tennessee 38113-0327 Phone: (901) 774-4370 • Fax: (901) 774-4666 • E-Mail: [email protected] • www.DrexChem.com iiili'.'. • • ~ ..... NOTIFICATION •

JUN 3 0 2004 • ••••• • •••• ••• • • ~"'IP" • •••• •

ACTIVE INGREDIENT: Cupric hydroxide' ...... 37.5% PPE. II OTHER INGREDIENTS: ...... 62.5% water. TOTAL: ...... 100.0% *Metallic copper equivalent is 24.4% USER SAFETY Users should: 1) Wash hands before eating, drinking, chewing gum, KEEP OUT OF REACH OF CHILDREN using tobacco or using the toilet. 2) Remove clothing immediately if pesticide gets inside. Then wash thoroughly and put on clean cloth­ ing. 3) Remove PPE Immediately after handling this product. Wash the outside of before As soon as possible, wash CAUTION Inlo See FIRST AID Below ENVIRONMENTAL HAZARDS SHAKE WELL BEFORE USING This product is toxic to fish and aquatic organisms. For terrestrial uses, do not apply directly to water, or to areas where surface water is present EPA Reg. No. 19713·301 or to Intertidal areas below the mean hlghwater mark. Drift and runoff EPA Est. No. 19713·GA·1 Net Contents: from treated areas may be hazardous to fish and aquatic organisms in --- adjacent aquatic sites. Do not allow rinsate from cleaning of equipment FIRST AID to enter surface or ground water. CHEMIGATION INFORMATION IF SWALLOWED: Apply this product only through sprinkler irrigation system(s), including • Call a poison control center or doctor immediately for treatment advice. center pivot, lateral move, end tow, side (wheel) roll, traveler, big gun, • Do not giw any Hqlid to the person. • Do not induce 'vOmiting unless told to do so by a poison control center or solid set or hand move. 00 not apply this product through any other type doctor. of irrigation system. ·00 not give anyttlng by mouth to an unconscious or corMJIsing person. Crop injury, lack of effectiveness or illegal pesticide residues in the crop can result from non-uniform distribution of treated water. IF IN EYES: If you have questions about calibration, you should contact State • Hold 6)e open and rinse slowly and gently with water for 15 to 20 mir'K,:tes. Extension Service SpeCialists, equipment manufacturers, or other • Remove contact lenses. if present. after the first 5 minutes, then contlrAA:l experts. rinsing eye. Do not connect an irrigation system (including greenhouse systems) IF ON SKIN OR CLOTHING: used for pesticide application to a public water system unless the • Take off contaminated clothing. pesticide label-prescribed safety devices for public water systems are • Rinse skin immediately with plenty of water for 15 to 20 minutes. in place. IF INHALED: A person knowledgeable of the chemigation system and responsible for • Move person to fresh air. Its operation or under the supervision of the responsible person, shall o If person is not breathing, call 911 or an ambulance. then give artificial shut the system down and make necessary adjustments should the need respiration, preferably mouth-to--rnouth, if possible. al/.98. Call a pOison control center or doctor for treatment advice. Have the product RECOMMENDATIONS container or label with )Qu when calling a polson control center or doctor, or Keep agitator running in supply tank during irrigation operations. Apply going for treatment. For infonnatlon on this pesticide product, including health continuously for the duration of the water application. concerns, medical emergencies or pesticide incidents, call the National Mixing Instructions for dilution of pesticide In supply tank: Pour Pesticide "'ormation Center at 1-800-8SS.7378. label-recommended amount of this product on surface of water in nearly filled mixing tank or pre-mix in a bucket before pouring into mixing tank. Keep agitator running during filling. 00 not allow mixture to stand in PRECAUTIONARY STATEMENTS irrigation equipment. This product Is corrosive and equipment should be Hazards to Humans and Domestic Animals cleaned thoroughly after each day's spraying. CAUTION: Harmful if absorbed through the skin. Harmful if swal- POSTING lowed. Causes moderate eye irritation. Avoid contact with skin, eyes, Posting of areas to be chemigated is required when: 1) Any part of a or clothing. Wash thoroughly with soap and water after handling and treated area is within 300 feet of sensitive areas such aa residential before eating, drinking, chewing gum or using tobacco. Remove and areas, labor camps, businesses, day care centera, hospitals, in­ wash contaminated clothing before reuse. Prolonged or frequently patlent clinics, nursing homes or any public areas such as schools, repeated skin contact may cause allergic reactions in some indi- parks, playgrounds or other public facilities not including public roads, viduals. or 2) When the chemigated area is open to the public, such as golf PERSONAL PROTECTIVE EQUIPMENT (PPE) courses or retail greenhouses. Some materials that are chemical-resistant to this product are listed below. If you want more options, follow the instructions for cat- egory A on an EPA chemical-resistance selection chart. Applicator. and other handlers must wear: Long-sleeved shirt Manufactured By: and long pants, chemical-resistant gloves made of any waterproof Drexel Chemical Company material such as polyethylene or polyvinyl chloride, shoes plus P.O.BOX13327, MEMPHIS. TN 38113-0327 socks. protective eyewear and dust/mist filtering respirator (MSHAI NIOSH approval number prefix TC-21C) or a NIOSH approved respirator .i." •••••* with any R. P or HE filter. (Continued)

KOP IS a registered trademark of Drexel Chemical Company • 301SP·0604++ KOp·HYDROXIDE Page 1 of 4 Posting must conform to the following requirements: Treated areas shall 1. The distance of the outermost nozzles on the boom must not be posted with signs at all usual paints of entry and along likely routes exceed three-fourths the length of the wingspan or rotor. 'i) 1 of approach from the listed sensitive areas. When there are no usual 2. Nozzles must always point backward parallel with the air stream paints of entry. signs must be posted in the corners of the treated and never be painted downwards more than 45 degrees. areas and in any other location affording maximum visibility to sensI­ Where states have more stringent regulations, they should be ob­ tive areas. The printed side of the sign should face away from the served. treated area towards the sensitive area. The signs shall be printed in English. Signs must be posted prior to application and must remain The applicator should be familiar with and take into account the in­ posted until foliage has dried and soil surface water has disappeared. formation covered in the Aerial Drift Reduction Advisory Informa­ Signs may remain in place indefinitely as long as they are composed tion section that follows. of materials to prevent deterioration and maintain legibility for the du­ Aerial Drift Reduction Advisory Information • •••• • ration of the posting period. Information on Droplet Size •••• All words shall consist of letters at least 2.5 inches tall, and all letters The most effective way to reduce drift large and the symbol shall be a color which sharply contrasts with their imme­ potential.t\·~·OVJply diate background. At the top of the sign shall be the words KEEP OUT, droplets. The best drift management strategy is to ""ply 'he largest droplets that provide sufficient coveN,_ ••d control. Applying larger followed by an octagonal stop sign symbol at least 8 inches in diameter droplets reduces drift potential, but I-'ill rfot if.applications -containing the word STOP. Below the symbol shall be the words PESTI­ z,revent~rift are made improperly, or under unfavorable enviro."'.... t.conditions CIDES IN IRRIGATION WATER. (see Wind, Temperature and Humlcftty: :,rcCTempe'ature Invefllons). SPRINKLER CHEMIGATION General Instructions Controlling Droplet Size •• • •• : •• The system must contain a functional check valve, vacuum relief valve, Volume - Use high flow rate noU.-ttl.spply thetitighSl!;t practical and low pressure drain appropriately located on the irrigation pipeline to spray volume. NozzJes with highe.I8&141ows produce~rger droplets. prevent water source contamination from backfJow. Pressure - Do not exceed the nozzle manufacturw~.,commended The pesticide injection pipeline must contain a functional, automatic, pressures. For many nozzle types, lower pressl!rl"p.qcftJces larger quick-closing check valve to prevent the flow of fluid back toward the droplets. When higher flow rates are needed, use l11gner flow rate injection pump. nozzles instead of Increasing pressure. : ••• The pesticide injection pipeline must also contain a functional, normally Number of nozzles - Use the minimum numl1St-t1J nozzles that closed, solenoid-operated valve located on the intake side of the injec­ provide uniform coverage. tion pump and connected to the system interlock to prevent fluid from being withdrawn from the supply tank when the irrigation system is Nozzle Orientation - Orienting nozzles so that the spray is released either automatically or manually shut down. parallel to the airstream produces larger droplets than other orientations The system must contain functional interlocking controls to automatically and Is the recommended practice. Significant deflection from horizontal shut off the pesticide Injection pump when the water pump motor stops. will reduce droplet size and increase drift potential. The irrigation line or water pump must include a functional pressure switch Nozzle Type - Use a nozzle type that is designed for the intended which will stop the water pump motor when the water pressure decreases application. With most nozzle types, narrower spray angles produce to the point where pesticide distribution is adversely affected. larger droplets. Consider using low-drlft nozzles. Solid stream nozzles Systems must use a metering pump, such as a positive displacement oriented straight back produce the largest droplets and the lowest injection pump (e.g., diaphragm pump) effectively designed and con­ drift. structed of materials that are compatible with pesticides and capable Boom Length of being fitted with a system interlock. For some use patterns, reducing the effective boom length to less Do not apply when wind speed favors drift beyond the area intended than three-fourths of the wingspan or rotor length may further reduce for treatment. drift without reducing swath width. DIRECTIONS FOR USE Application Height tt is a violation of Federal Law to use this product in a manner incon­ Applications should not be made at a height greater than 10 feet sistent with its labeling. Do not apply this product in a way that will above the top of the largest plants unless a greater height is required contact workers or other persons either directly or through drift. Only for aircraft safety. Making applications at the lowest height that is protected handlers may be in the area during application. For any re­ safe reduces exposure of droplets to evaporation and wind. quirements specific to your State or Tribe, consult the agency respon­ sible for pesticide regulations. Swath Adjustment When applications are made with a crosswind. the swath will be displaced AGRICULTURAL USE REQUIREMENTS dDwnwind. Therefore, on the up and downwind edges of the field, the Use this product only in accordance with its labeling and with the Worker e;tpplicator must compensate for this displacement by adjusting the Protection Standard, 40 CFR Part 170. This standard contains require­ palh of the aircraft upwind. Swath adjustment distance should increase, ments for the protection of agricultural workers on farms, forests, with increasing drift potential (higher wind, smaller drops, etc.) nurseries, greenhouses and handlers of agricultural pestlcides. It Wind contains requirements for training, decontamination, notification and Drift potential is lowest between speeds of 2 to 10 mph. However, emergency assistance. It also contains specific instructions and many factors. including droplet size and equipment type determine exceptions pertaining to the statements on this label about personal drift potential at any given speed. Application should be avoided below protective equipment (PPE). restricted entry interval (REI) and notifi­ 2 mph due to variable wind direction and high Inversion potential. cation to workers. The requirements in this box only apply to uses of Note: Local terrain can influence wind patterns. Every applicator should this product that are covered by the Worker Protection Standard. be familiar with local wind patterns. and how they affect spray drift. Do not enter or allow worker entry into treated areas during the Temperature and Humidity restricted entry interval of 24 hours. When making applications in low relative humidity, set up equipment PPE required for earty entry to treated areas that is pennitted under the Worker to produce larger droplets to compensate for evaporation. Droplet Protection Standard and that involves contact with anything that has been evaporation is most severe when conditions are both hot and dry. treated, such as plants, soil or water is: Coveralls, chemical-resistant gloves made of any waterproof material such as polyethylene or polyvinyl chloride, Temperature Inversions shoes plus socks and protective eyewear. Applications should not occur during a temperature inversion because drift potential is high. Temperature inversions restrict vertical air mixing, An eye-flush container, designed specifically for flushing eyes, must be which causes small suspended droplets to remain in a concentrated availableat the WPS decontamination siteforworkers entering the area treated with copper hyUroxide. cloud. This cloud can move in unpredictable directions due to the light variable winds common during inversions. Temperature inversions Notify workers of the application by warning them orally that residues in the are characterized by increasing temperatures with altitude and are treated areas may be highly irritating to their eyes and to take precautions such common on nights with limited cloud cover and light to no wind. They as refraining from rubbing their eyes and if they get residues in their eyes they begin to form as the sun sets and often continue into the morning. should immediately flush their eyes using a eye-flush container. Their presence can be indicated by ground fog; however, if fog is SPRAY DRIFT MANAGEMENT not present, inversions can also be identified by the movement of smoke from a ground source or an aircraft smoke generator. Smoke Avoiding spray at the application site is the responsibility of the that layers and moves laterally in a concentrated cloud (under low applicator. The interaction of many equipment- and weather-related wind conditions) indicates an inversion, while smoke that moves upward factors determine the potential for spray drift. The applicator and and rapidly dissipates indicates good vertical air mixing. the grower are responsible for conSidering all these factors when making decisions. Sensitive Areas This pesticide should only be applied when the potential for drift 10 The following drift management requirements must be followed to adjacent sensitive areas (e.g. residential areas, bodies of water, known avoid off-target drift movement from aerial applications to agricul­ habitat for threatened or endangered species, non-target crops) is tural field crops. minimal (e.g. when wind is blowing away from the sensitive area).

KQP·HYDRQXIDE Page 2 of 4 Use this product as noted below. This product is adaplable to spraying CANTALOUPES, HONEYDEWS, MUSKMELONS: Downy mildew _ Apply l.'":") --7 ~. from all types of spray equipment. Depending on the equipment used weekly at 2.7 pints per acre before disease appears. 7 and the specific crop, the volume applied per acre will differ. For dilute, CARROTS: Carrot blight (Cercospora) - When disease threatens, apply 2.7 high volume sprays, use from 25 to 100 gallons of water per acre for pints per acre at 7 to 14 day intervals. depending on disease severity. most vegetable crops, 400 to 800 gallons per acre for fruit orchards and CELERY: Early. Late and Bacterial blights - Apply as soon as plants are first up to 1,500 gallons per acre as may be required for large citrus groves. established in the field at 2.7 pints per acre, then every 5 to 7 days depending For concentrate ground sprays, apply from 5 to 20 gallons per acre for on severity and weather. One to two Quarts of a suitable agricultural spray oil per most vegetable crops and 25 to 100 gallons per acre for ·fruit and nut acre may be used as spreader-sticker. crops. For aerial spraying, 3 to 15 gallons per acre are commonly used. CHERRY: COl)'Tleum blight (Shot hole), Dead bud (Pseudomonas syringee) - No additional surfactants are needed. Add this product slowly to a spray Apply 8 pints plus 1 pint of superior-type oil per 100 gallon& ~ber (before tank partially filled with water. Spreader-stickers, insecticides, nutrients. heavy Fall rains) and again in January. In orchards where the diS8C'-ie is severe, etc. should be added last. Observe all cautions and limitations on label a spray should also be applied in August...... of all products used in mixtures. The following specific instructions are Brown rot blossom blight - For adequate control apply2. 7 t~""lhr,;'fy 100 gallons based on general applications. The recommendations of Ihe State Agri­ as a full cover spray at popcom and full bloom. • • • cultural Extension Services should be closely followed as to timing, fre­ CITRUS: Greasy spot, Melanose, Pink.,~g,.%ab - Apply ¥ pre-bloom and _Quency and number of sprays per season. post-bloom sprays. Use 1 to 2 pints of "'is P'Odect per 100 gallons, depending ALFALFA: Cercospora and Leptosphaerulina leaf spots - Apply at 2.7 on disease severity. May be used in co"centrate·sprays aZ ~alent rates. For pints per acre 10 to 14 days before each harvest or earlier if disease aerial application, use 8 pints of this prtfd!lf"e..,O galloPis per acre. Brown rot threatens. Apply with ground or aerial equipment. Spray injury may oc­ - Use 0.7 to 1.7 pints per 100 gallons as diI~Ef spray or itA'ilivalent rate as cur with sensitive varieties such as Lahontan. concentrate spray, depending on seve!J.f¥ ~f disease. BE!bin aJ>plltation in Fall ALMONDS: Coryneum blight (Shot hole), Blossom brown rot - Use 2.7 before or just after first heavy rains. ApPly t. ;k~r1B of trees fa ~ he~ht of at least to 4 pints of this product per 100 gallons of water (300 to 400 gallons 4 feel. Apply also to bare ground one 'If>t ~nd skirt. • per acre) in late dormant before foliage buds swell if frequent rainfall CA ONLY: In areas subject to copper injury, add 0.3 to 1 poIIIliXitof high quality occurs. A second application should be made during the early bloom lime per 1.3 pints of this product. • •••• stage (popcorn). To avoid plant injury, do not use above rate after full COFFEE: Iron spot (Cercospora coffeico/a), Pink disease (Corticium bloom. sa/monic%r) - Apply at 2.7 pints per acre as a conGttnlrtte or dilute Bacterial blast (Pseudomonas) - Use 4 to 5.3 pints of this product per spray. Begin treatment at start of wei season and -=-_inue at monthly 100 gallons at dormant to early pink bud. For Blast control in sprinkler intervals for three applications. Leaf rust (Brazil) - Apply 4.7 to 7.3 irrigated orchards or where disease is severe, apply 2 10 4 sprays of pints per acre for average density plantations. High denSity plantations this product at one-third pint per 100 gallons at 2-week post·bloom inter­ may require 9.3 to 10.7 pints per acre. Make application from Seplember vals or just before sprinkling. Slight leaf injury may occur from post­ to March depending on altitude and local recommendations. Apply 3 to 4 bloom spray. week intervals, depending on disease severity and rainfall conditions. APPLE: Anthracnose, European canker, Pseudomonas syringae - Apply CRANBERRY: Fruit rot - Apply at 10.7 pints per acre beginning in late before Fall rains at 4 to 5.3 pints per 100 gallons (300 to 400 gallons per bloom. One or two additional applications made at 10 to 14 day intervals acre). Use on yellow varieties may cause discoloration. To avoid, pick may be required, depending on disease pressure. Follow the advice of before spraying. Firebllght - Apply at 2.7 to 5.3 pints per 100 gallons the State Agricultural Extension Service. of water as a full cover spray. Make application between silver tip and CUCUMBERS: Angular leaf spot. Downy mildew - Apply weekly once green-tip. the plants begin to vine. Use 2 to 2.7 pints per acre. Note: Phytotoxicity may occur from late application. (Discontinue use CURRANTS, GOOSEBERRY: Leaf spot - Make three applications of when green-tip is one-half Inch.) this product at 13.3 pints per acre starting after harvest, before bloom Crown or Collar rot (Phytophthora cactorum) - Mix 5.3 pints in 100 gal­ and after pelal fall. lons of water. Apply 4 gallons of suspension as a drench on the lower EGGPLANT: Alternaria blight. Anthracnose, Phomopsis - Use 2.7 pints trunk area of each tree. Apply either in early Spring or in Fall after har­ of this product per acre before disease appears. Repeat at 7 to 10 day vest each year. Do not use if soil pH Is below 5.5 or copper toxicity intervals. (EXCEPT CA.) may result. (EXCEPT CA). FILBERTS: Bacterial blight - Apply 5.3 to 8 pints plus 1 pint of supe· APRICOTS: Blossom brown rot, Coryneum blight (Shot hole) - Apply at rior-type oil per 100 gallons in late August or early September. In sea­ popcorn to full bloom using 2.7 to 4 pints per 100 galions (300 to 400 sons of heavy rainfall, apply another spray when three-fourths of the gallons per acre). To avoid spray injury, do not apply after bloom. leaves have dropped. AVOCADOS: Scab - Apply when bloom buds begin to swell at 2.7 pints GRAPES: Black rot, Downy mildew, Powdery mildew - Apply 2.7 pints of this product per 100 galions or 10.7 to 13.3 pints per acre dependmg of Ihis product plus 2 to 6 pounds of hydrated lime per acre as a dilute on equipment. Continue application at monthly intervals for 5 to 6 appli­ cr c;oncentrate spray. Use this product for the last one or two late Summer cations. Follow recommendations of State Agricultural Experiment Sta­ aJ)plications following early season application of another fungicide. Follow tions. State schedule for exact timing. BANANAS: Sigatoka - Apply by air at 2.7 pints per acre in 3 gallons of Note: Slight to severe foliage injury may occur on copper-sensitive varieties water containing one-half galion of agricultural oil. Apply on a 14 day such as Concord, Delaware, Niagara and Rosette. schedule throughout the wet season. Apply at 21 day intervals during HOPS: Downy mildew - Apply 2.7 pints as a fungicide crown treatment dry periods. (after pruning, but before training) as needed. After Iraining, additional Black pitting - Apply at 5.3 pints per 100 gallons directly to Ihe fruit fungicide treatments are needed at about 10 day intervals. Discontinue stem and include the basal portion of the leaf crown. Apply during the use 2 weeks before harvest. first and second weeks after emergence. LETTUCE: Downy mildew - Apply 1.3 to 2.7 pints of this product per BEANS: Bacterial blight (Halo and Common) - For protective sprays, acre. Begin treatment when disease first appears and repeat every 7 to apply first application when plants are six inches high. Apply on 7 to 14 10 days as needed to suppress disease. day schedule depending on local conditions. Use 1.3 to 4 pints per acre, LIVE OAK: Ball moss (TX Only) - Apply at 8 pints per 100 gallons of depending on disease severity. water in Spring after heavy rain, using 1.5 gallons of spray per foot of BLACKBERRIES (Auroras, Boysens, Cascades, Chehalems, Logans. tree height. Make sure to wet tufts thoroughly. A second application may Marlons, Santlams, Thornle.s evergreens): Leaf and Cane spot - be required after 12 months. Apply delayed dormant spray after training in Spring at 5.3 pints plus 1 MANGO: Anthracnose (FL) - Apply monthly after fruit set until harvest quart of superior-type oil per 100 gallons. Apply again in late Spring at at 2.7 pints of this product per 100 gallons or 10.7 to 13.3 pints per acre 2.7 pints plus 1 quart of superior-type oil per 100 gallons. Make full depending on equipment. Consult Extension Service for Stale recom­ spray application after harvest using 5.3 pints plus 1 quart of superior­ mendations. type oil per 100 gallons. OLIVES: Peacock spot (CA) - Make first application at 2.7 to 4 pints BROCCOLI, BRUSSELS SPROUTS, CABBAGE, CAULIFLOWER: Downy per 100 gallons or at 10.7 to 16 pints per acre, depending on equipment, mildew - Apply 0.7 to 1.3 pints in a minimum of 25 gallons per aCte before Winter rains fall. A second application in early Spring should be at 7 day intervals. (Cabbage Only). Black leaf spot (Alternaria). Black made if disease is severe. rot (Xanthomonas) - Apply at 2.7 pints per acre in a minimum of ONION: Downy mildew. Purple blotch - Apply 2.7 pints of this product 25 gallons per acre at 7 to 10 day intervals. per acre when plants are 4 10 6 inches high and repeat at 7 10 10 day Note: A slight reddening of older leaves may occur on Broccoli and a intervals. slight flecking of wrapper leaves may occur on Cabbage at Ihe 2.7 pints PEACHES, NECTARINES: Coryneum blight (Shot hole), Leaf curl - rate. For control of diseases of these crops, begin applications after Dormant application: Apply at leaf fall. Dilute: Apply 2.7 to 5.3 transplants are set in the field or shortly after emergence of freid-seeded pints per 100 gallons (minimum of 10.7 pints per acre). Use 21.3 pints crops or when conditions favor disease development. per acre when rainfall is very heavy and disease pressure is high. CACAO: Black pod - Begin applications at the start of the rainy season Concentrate: Apply at equivalent rates in approximately 100 gallons and continue while infection conditions persist. Sprays should be made of water. May be used with agricultural spray oiL Blossom blight, Brown as often as 14 to 21 days in high rainfall areas at varying rates from rot - Apply at 2.7 to 4 pints per 100 gallons as full cover spray 2.7 to 6 pints per acre, depending on disease severity, For drier areas, at pink bud. (Application at this time also affords some control of where 2 to 4 applications are recommended during critical infection peri. Coryneum blight and Leaf cun). Bacterial spot - Dormant application: ods and at long intervals, use 8.7 to 11.3 pints per acre, according 10 Apply at 2.7 pints per 100 gallons Post-bloom. apply 0.3 pint per disease incidence and planting density. KOp·HYDROXIDE Page 3 of 4 100 gallons at first and second cover sprays. Do not spray later than WALNUT: Walnut blight - Apply first spray at early pre·bloom when three weeks prior to harvest. Do not use at rates above those rec~ catkins are partially expanded. Make three additional applications during ommended. bloom and early nutlet stages at 7 to 10 day Intervals. Additional appU~ Note: Slight defoliation and spotting of leaves may occur from use in cations may be necessary when frequent rainfall occurs. Dilute: Apply cover sprays. 2.7 pints per 100 gallons of water (minimum of 10.7 pints per acre). PEANUTS: Cercospora leef spot - Begin spraying 40 to 45 days after Concentrate: Apply at equivalent rates in 50 to 100 gallons water per planting or when disease symptoms appear. Make ground or. aerial appli~ acre. One pint of Summer oil emulsion may be added per 100 gallons of cation at 2 to 4 pints per acre. For aerial application, use 3 to 10 gallons spray. Do not apply more than 16.7 pints per acre per application. of water. Continue applications at 10 to 14 day intervals. Use sufficient WATERMELON: Anthracnose, Downy mildew - Apply as soon as plants water to get adequate coverage. This product may be tank~mixed with become established and at weekly. intervals thereafter;. ~"lJ'racnose - flowable sulfur products. Use at 2.7 pints per acre. Downy mildew - Use at 2.10 4 plnls per acre PEARS: Fire blight - Apply at one~third pint per 100 gallons or 1.3 pints according to disease severity. • ••• per acre at 5 day intervals throughout bloom period. Pseudomonas blight WHEAT, BARLEY: Helminthosporium spot blotch, Sep:l«il!l~.af blotch - - Apply this product before Fall rains at a rate of 4 to 5.3 pints per 100 Apply 2 to 2.7 pints per acre. Make first application '~~y~ot stage gallons (300 to 400 gallons per acre) and again at dormant before Spring and follow with second application at ea~ly head stage. .9rowth starts. Excessive dosages may cause Fruit russet. STORAGE AAtl DISPOSAL. PEAS: Powdery mildew - Begin spray treatment when disease symp~ ... , .. toms first appear. Use at 2 to 4 pints per acre according to disease Do not contaminate water, food or fHdtlt}"llorage ...d disposal. severity. Repeat applications at weekly intervals. PESnCIDE STORAGE: Store unused ~ in origil1jll. ~tainer only PEPPERS: Bacterial spot - When disease threatens, apply 2.7 to 4 in cool, dry area out of reach of children and altimale. • pints per acre in sufficient water for adequate coverage at 7 to 14 day PESnCIOE DISPOSAL: Wastes restltillg· ~ the us3 tf thfs product intervals, depending on disease severity. may be disposed of on site or a.-~ftJ\ted waste dis,osal facility. PHILODENDRON: Bacterial leaf spot - Apply weekly before disease CONTAINER DISPOSAL: Triple rinse (or equivalent)l.Tl1(1n offer for appears at 2 pints of this product plus manufacturer's recommended recycling or reconditioning or puncture and dispose 01 in a sanitary amount of mancozeb per 100 gallons of water. landfill, or by Incineration if allowed by State and L~ -authOrities. POTATOES: Early and Late blight - Apply at 7 to 10 day intervals start· If burned, stay out of smoke. : ' •• ing when plants are six inches high until two weeks before harvest. Use ... " 1.3 to 2 pints per acre in those locations where disease is light and up WARRANTY-CONDITlONS OF SALE to 4 to 5.3 pints per acre where disease is more severe. OUR RECOMMENDATIONS FOR USE of this product are based upon PUMPKIN, SQUASH: Powdery mildew - Begin applications when plants tests believed reliable. Follow directions carefully. Timing and method are 3 weeks old or when first disease symptoms appear. Use at of application, weather and crop conditions. mixtures with other chemicals weekly intervals at 2 to 4 pints per acre, depending on disease not specifically recommended and other influencing factors in the use severity. of this product are beyond the control of the Seller. Buyer assumes STRAWBERRIES: Leaf blight, Leaf spot - Apply at 2.7 to 4 pints in all risks of use, storage and handling of this material not In strict 100 gallons per acre. Begin application when plants are established and accordance with directions given herewith. In no case shall the Manu­ continue on a weekly schedule throughout season. Discontinue applica­ facturer or the SeUer be liable for consequential, special or indirect tions if signs of phytotoxicity appear. damages resulllng from the use or handling of this product when such SUGAR BEETS: Cercospora leaf spot - Start spray when disease threatens use and/or handling is not in strict accordance with directions given and continue 4 to 5 applications. Spray at 10 to 14 day intervals, de· herewith. The foregoing is a condition of sale by the Seller and is pending on weather conditions, at 2.7 to 6.7 pints per acre, depending on accepted as such by the Buyer. disease severity. Addition of suitable agricultural spray oil is recommended at 2 quarts per acre. SYCAMORE: Anthracnose - Make two applicatlons using 2.3 to 4 pints per 100 gallons as a full cover spray. Make first application at bud crack and second application 7 to 14 days later at 10% leaf expansion. TOMATOES: Early blight - When disease threatens apply 2.7 to 4 pints per acre at 7 to 10 day intervals. Bacterial speck - Apply at 2.7 pints per acre at 10 to 30 day intervals beginning when the disease threatens. Use more frequent applications when disease pressure is high. Bacterial spot - When disease threatens apply 2.7 to 5.3 pints per acre at 1 to 10 day intervals, more frequently when disease is severe. This product may be combined with maneb or mancozeb. Do not apply within five days of harvest.

KOP-HYDRQXIDE Page 4 of 4 •

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Drexel Chemical Company •••• , , • • '"I' •••• • •••••• June 14, 2004 •• • I·•••••• •• • • • ••••••• • ••••••• • • •• • •••••• Document Processing Desk (NOTIF) •••••• • •• • Office of Pesticide Programs (7504C) "" ",~, .... ~ • U.S. Environmental Protection Agency •••• • •••• • Rm 266A, Crystal Mall 2 ,,!', •••• 1921 Jefferson Davis Hwy. ••••• Minglon, VA 22202

Re: Submission ofReitised Label by NotlflCtltlon per PR N~ce 95-1 tInd Oth~ ,',' DREXEL KOP-HYDROXIDE (EPA Reg. No. 19713-301) ,','" ' " '

'~' , Herewith:

1. Completed EPA Form 8570-1. , " were 2. One (1) copy of the revised label (301SP-0604++). The foHowing changes'/.: made on the label: ".'~,',,::~~N-·~~' ~;;" ,,","~ '." ',~" :" .....-'< i) In the Environmental Hazards section, the paragl1iph, ""Note: 'Addlh~stafeme!lIIO 'all container sizes ...... Office of the EPA.' was deleted. Per PR Notice 95-1, this only applies to end-use products registered for industrial preservative, water treatment, other industrial processing uses and commercial and institutional uses.

ii) Under Spray Drift Management, 'downward" was corrected to 'downwind' under the subheading 'Swath Adjustment'

3. Certification Statement

If you have questions/clarification regarding this submission,l can be reached at (901) 774-4370. My e-mail addressisl.:[email protected].

Thank you.

Respectfully yours, FOR DREXEL CHEMICAL COMPANY I! _C ~'>V ~;~~ Registration Manager

1700 Channel Avenue· Post Office Box 13327 • Memphis, Tenne.. ee 38113·0327 Phone: (901) 774·4370 • Fax: (901) 774·4666 • E·Mall: [email protected] • www.DroxChem.com iii.• ,." ••